The hazard communication system (HCS) regulations are covered in 29CFR1910.1200. Subsection (g) provides requirements for safety data sheets (SDSs).
The first requirement is that chemical manufacturers and importers must obtain or develop an SDS for each chemical [1910.1200(g)(1)]. What this means for your purposes is that every chemical will have an SDS associated with it. It also means you should not permit any chemical to be on your site unless you have its SDS.
Many years ago, the format of the SDS was standardized such that all will have the same 16 sections (additional sections are optional, as the need dictates) enumerated 1 through 16. The requirements for these sections are enumerated, logically enough, in 1910.1200(g)(2)(1) through (16). For example, Section 3 always has the composition information on ingredients while Sections 4 and 5 have the first-aid and firefighting measures, respectively. The standardization allows users to pick up an SDS they have never seen before and know right where to look for the information they need.
Other requirements follow, such as the one that an SDS must be included with each shipment [1910.1200(g)(6)]. This gives rise to a question. What if you pick up a given chemical at your electrical distributor’s shop? They aren’t shipping it to you, and they aren’t the manufacturer or (presumably) the importer, so are they required to provide the SDS? There’s a two-part answer:
- If it’s not provided, you (the employer) must obtain one from the chemical manufacturer as soon as possible [1910.1200(g)(6)(iii)]. And they are required to honor your request for one [1910.1200(g)(6)(iv)].
- Retail and wholesale distributors selling hazardous chemicals to employers must post a sign stating SDS are available upon request (or otherwise inform employers of this), and they must provide one upon request [1910.1200(g)(7)(iii) and (iv)]. There are some nuances here, for example the retail requirement applies only when the employer has a commercial account.
The employer must maintain in the workplace copies of the SDS for each chemical used in that workplace [1910.1200(g)(8)]. An exception exists where employees travel between workplaces during a workshift; in that case the SDS can be kept at just the primary workplace [1910.1200(g)(9)].
You can keep your SDS in any form, including operating procedures [1910.1200(g)(10]. They may even be designed to cover groups of chemicals, in a work area where it may be more appropriate to address the hazards of a process rather than the individual hazardous chemicals.
Make it a policy that you don’t allow a chemical on your site or in your facility without an SDS, whether you have to contact the manufacturer, distributor, or retailer. And make the SDS for any hazardous chemical used on a given site readily available to employees who work on that site.
